Anti-corruption: At DTT member firms 2007/2008
DTT and its member firms continue to leverage the DTT ethics program to reinforce the importance of ethics and integrity across the organization.
Leadership and accountability
Since its inception, DTT’s global ethics program has been led by a Global Chief Ethics Officer who has direct accountability and responsibility for the program’s planning, priorities, and resources. Annual formal reporting to the DTT Board and direct, unfettered access to DTT’s global CEO allows the DTT Chief Ethics Officer to freely raise issues and new ideas to the highest levels of the organization.
Ethics communication has been front and center for DTT and its member firms in 2008 with the introduction of a new internal blog entitled “ Bob’s adventures in ethics.” Bob, a fictional Deloitte member firm employee, writes about real ethical problems at work. Monthly stories relate directly to ethical principles and provide guidance on how to handle difficult situations. People at Deloitte member firms have an opportunity to post thoughts and solutions to Bob’s dilemmas on the blog, thereby generating a dialogue about the importance of ethics and integrity in the workplace. Since the roll-out of Bob’s blog in February 2008, there have been more than 40,000 unique visitors and hundreds of postings.
DTT and its member firms continue to build on commitments to ethics in learning. This year, ethics related content was integrated into two important global learning programs: Leadership Excellence and Management Excellence. These programs reach thousands of Deloitte member firm people each year and going forward, participants will be exposed to ethical dilemmas, case studies, and discussions to help them analyze issues and consequences and make thoughtful ethical decisions using a structured decision-making model. This new integrated content builds on the DTT ethics e-learning program and helps make ethics a natural part of dicussions.
Reporting and measurement
Member firm ethics practice reviews continue to be an important tool for measuring the effectiveness of member firm ethics programs. The practice reviews use a compilation of member firm leadership interviews, data review, and employee focus groups to test and validate compliance with ethics policies as well as identify ethics program best practices to share across member firms. By the end of 2008, 30 such reviews will have been completed.
2008 is the second year that DTT and nearly 40 of its member firms have implemented the Global Ethics Survey. This survey solicits anonymous feedback to measure member firm employees' awareness and perceptions of member firms' ethics programs and culture of integrity. Member firms are able to benchmark their performance over time to drive continuous improvement.
A compliance framework has been introduced this year within the member firms of DTT. This framework describes how member firms should measure and report their compliance with DTT and local policy standards. In accordance with this framework, each member firm will be responsible for providing annual written confirmation that they are in compliance with all DTT and member firm ethics policies.
Select member firm examples:
- Deloitte South Africa has developed a unique solution, Tip-offs Anonymous®, allowing for the anonymous reporting by staff of unethical business practices and dishonesty in the workplace. The fraud-combating tool has been implemented both in the member firm and in client offices as a service from the firm, where it operates independently (see " Working with clients"). It enables the partners, directors, and staff of the member firm to raise alerts around inappropriate practices in a completely confidential manner.
- The DTT Global Audit Curriculum has a strong anti-fraud focus at all levels. There are specific learning units for different member firm career levels. At more junior levels, the learning introduces aspects of fraud and how audit procedures can be designed to have the best chance of detecting management fraud. At more senior levels, the learning focuses on more complex fraud schemes. Also, the 2008 Audit Excellence Program, offered to all member firm partners and managers, has a strong focus on fraud within the context of the current economic climate and the potential impact this may have in increasing motivation/incentive in individuals in management positions to commit fraud.
- The Deloitte U.S. Firms'* State and Local Compliance Manual addresses rules against bribery for each of the member firm's state clients and provides general guidance to all public sector practitioners. The Manual addresses topics such as campaign finance; gifts, gratuities, and bribery; lobbying; conflicts of interest and post-employment restrictions; outsourcing, and procurement and procurement integrity.
- Deloitte Central Europe has developed an Anti-Money Laundering Policy that every employee is required to comply with in order to ensure that Deloitte Central Europe does not become involved in any money laundering activity or terrorist financing. An e-learning course on the policy has been developed, and anti-money laundering officers have been appointed for every country in the Deloitte Central Europe member firm.
- Deloitte Australia performs periodic internal reviews of payroll, expense claims, and annual leave balances to detect any inappropriate activity. For departing partners and employees, or when there is suspected misconduct, the member firm is able to use its Computer Forensics team to perform a review of the departing person's laptop. In addition, an internal audit function focuses on fraud across the organization.
- At Deloitte Canada, all partners, associate partners, and external client service personnel in Financial Advisory and everyone in Internal Client Service Finance are required to complete an "Anti-Money Laundering and Terrorist Financing" e-learning course. A basic awareness presentation on the topic is also available to all employees.
- At Deloitte Argentina, all new hires must complete e-learning on ethics, independence and security.
- Deloitte U.S. Firms* offer a confidential 24-hour, year-round Integrity Helpline that anyone can access from any location. It is administered by a third party to help maintain confidentiality and, when requested, anonymity to the extent possible. Employees are encouraged to report potential violations of the law, regulations, professional standards, policy, or the member firm's Code of Ethics and Professional Conduct.
*As used in this reporting, "Deloitte U.S. Firms" means Deloitte LLP and its subsidiaries.
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